This is a formal request to
have my second stage complaint considered by the BBC Trust.

Following my initial enquiry
and a subsequent reply to the points raised, I believe that no serious or
satisfactory consideration of my concerns has been offered.

The essence of my complaint
can be gleaned from the correspondence to date, which reads as follows:

Original letter to BBC

(29 March 2013):I'd like to request that the BBC
end its selective use of Iraq Body Count (IBC) when denoting civilian war deaths
in Iraq.The issue of BBC bias towards
IBC and the false impressions it serves is discussed here.As noted, the following suggests a
simplified alternative which, rather than IBC's limited and misleading count,
offers a more informed and balanced range of figures:Civilian war deaths in Iraq
(range): Iraq Body Count (IBC)
(till Dec 2012) 110,937 - 121,227
Lancet/Johns Hopkins survey
(March 2003 - end of June 2006)
654,965 Opinion Research Business
(ORB) survey (August 12–19, 2007)
1,033,000Source: Wikipedia
Please consider replacing sole
reference to IBC with this fairer and more viewer-serving graphic.
The use of IBC as an
'authoritative' and singularly-mentioned figure is widespread across the BBC,
which suggests that a specific executive/editorial decision has been taken in
this regard.I'd like to see any copy or/and
details of that decision-making process.As the BBC's own charter/editorial
guidelines specify a requirement to be
neutral and impartial, I look forward to a fairer presentation of this key
information. If such an alteration is not undertaken, I intend to seek a ruling
on this matter from the BBC Trust. For the purposes of this
complaint, I cite the following online report and its singular, biased use of
IBC figures: Iraq 10 years on: In
numbers

I look forward to your
reply.RegardsJohn Hilley

------------------------------

Reply from BBC's Gemma
McAleer

(17 May
2013):

Dear Mr HilleyThanks for contacting
us.Please accept our apologies for
the delay in replying. We know our correspondents appreciate a quick response
and we’re sorry you have had to wait on this occasion.[Administrative
details...]We forwarded your concerns to
the BBC News website team who respond to your concerns as
follows:"We have reported over recent
years on the various attempts to catalogue the death toll in Iraq, and on the
controversy surrounding the different figures.http://www.bbc.co.uk/news/world-middle-east-11107739
http://news.bbc.co.uk/1/hi/uk/6045112.stm
http://news.bbc.co.uk/1/hi/world/middle_east/7180055.stm
http://news.bbc.co.uk/1/hi/world/middle_east/3962969.stm
The Iraq Body Count is the only
organisation to offer an actual count covering the period since the US-led
invasion. Other organisations seek to estimate the death toll at particular
points in time, using statistical and sampling techniques. In the particular graphic you
cite, we attempt to show the rise and fall in deaths and casualties over the 10
years since the invasion. The Iraq Body Count is the only source that we feel we
can rely on for this specific data. This graphic is not about numbers, but about
the pattern over that period and other sources do not provide this
information."Please be assured that your
complaint has been registered.Thanks again for getting in
touch.

(19 May 2013):Dear Gemma
McAleerThe deceit and evasion in
your reply is glaringly obvious.The first link here gives
distinct prominence to IBC, with only cursory mention of Lancet/Johns Hopkins
and no mention of ORB, the others providing only basic news/assessment of the
Lancet study and Iraqi Family Health Survey.However, the issue is not just
about discussions of those latter studies - sparse as they are in overall BBC
output - but, more specifically, fair and equal presentation of such
sources/data in viewer graphics.It's clearly evident that the
BBC has selected IBC's data because it reflects UK/US war killing in its least
damaging light. Your every excusing word makes the BBC complicit in disguising
that crime.

Also, if, as you claim, the point
of the graphic is "not about numbers", why insist on a count-based graphic at
all?And even if it's about showing
"a pattern over that period", why still exclude illustration of the other
studies?I've suggested that, for balanced
information, the BBC could show a (simplified) caption with all these sources
and their respective data. Why is this so problematic?I've also asked for specific
information on who at the BBC made the editorial decision to 'adopt' IBC and how
that decision was arrived at. Since neither that nor a
satisfactory answer to my question about using additional sources has been
received, I wish to have my enquiry elevated to 'stage 2' consideration.
RegardsJohn Hilley

-------------------------

To BBC's Fran
Unsworth

(19 June
2013)

Reference
CAS-2109403-3PN7BB

Dear Fran Unsworth

Further to my initial correspondence, I wish to elevate my complaint to a
second stage enquiry.

I assume from the above
reference supplied by the BBC that you have details of my original letter and
the BBC's reply.

Here is the text of my last
response:

[As to Gemma
McAleer, above.]

Since my original request,
the results of a significant poll have been published showing that the general
public have been very poorly informed as to the extent of war-related fatalities
in Iraq:

A key reason for this must surely be the media's failure to present that
core information to the public. As a leading news organisation, supposedly
dedicated to the provision of wide and balanced information, the BBC must take a
considerable level of responsibility for that failure.

I wish to offer this poll evidence in support of my above-noted request for
an explanation as to why the BBC has favoured the IBC data and how that decision
was arrived at.

I look forward to hearing your considered thoughts.

Kind regards

John Hilley

-------------------------

Reply from BBC's Stephanie
Harris

to second stage complaint letter

(17 July
2013)

Dear Mr
Hilley

As you know, your
concerns have been passed to me to respond to as it is my role to investigate
complaints at the second stage of the BBC ‘s complaints process on behalf of the
Director of BBC News. I realise that this
will disappoint you but there is very little that I can usefully add to the
responses you have already received and which I endorse.

You refer to the
lack of a reference to ORB in this report: http://www.bbc.co.uk/news/world-middle-east-11107739 but this
article was just given as an
example of how we have reported on the issue of numbers of civilian deaths in
the past. For now, the question is why we
didn’t put the range of sources in our recent coverage ten years on from the
invasion.

When looking at Iraq
ten years on, we wanted to give a sense of the scale of what has happened over
time and only the Iraq Body Count figures are able to do that. If you look at the graph in this
case, the movements are so small as to be imperceptible. As previously explained,
what matters here is the pattern over a number of years.

Other agencies cannot
provide this information so the Middle East editor felt that IBC was the right
source in this instance. Using other studies as
well – based on different methodologies – would have been pointless and
confusing for readers.

In concluding, I should point out that it is now open to you to ask the BBC Trust to review your complaint on appeal. However, please note that the Trust does not consider every appeal brought to it. In general, the Trust only considers those appeals which may result in a breach of the BBC’s Editorial Guidelines. If a question arises as to whether an appeal ought to be taken, the Trust is the final arbiter.

Appeals must be received within
20 working days of the date of this email. The Trust may, exceptionally, take an
appeal brought after this date if it considers there is a good reason for the
delay. The appeal should not exceed 1,000 words and should clearly state the
points you raised at Stage 2 which you want the Trust to address, with your
reasons. The Trust will not normally consider new points. You can find full
details of the complaints procedures here: http://www.bbc.co.uk/bbctrust/governance/complaints_framework/

Correspondence for the Trust
should be addressed to the Complaints Adviser, BBC Trust Unit, 180 Great
Portland Street, London W1W 5QZ or to trust.editorial@bbc.co.uk. If you have any access
issues please contact the BBC Trust for assistance on 03700 103 100 or textphone
03700 100 212.

Yours
sincerely

Stephanie
Harris

Head of Editorial
Compliance & Accountability

BBC News

-----------------------------

Reply to Stephanie
Harris

(19 July
2013)

Dear Stephanie
Harris

You have failed to
answer my questions.

Allow me to go through the
main parts of your letter:

"As you know, your
concerns have been passed to me to respond to as it is my role to investigate
complaints at the second stage of the BBC ‘s complaints process on behalf of the
Director of BBC News. I realise that this
will disappoint you but there is very little that I can usefully add to the
responses you have already received and which I endorse."

Actually, no, I'm not in the least disappointed. Disappointment usually only comes on the back of hopeful expectation. In this case there was no sense in which I expected anything other than what's stated here: blanket dismissal and paltry excuses.

As already stated, this article is token, both in its discussion of ORB and against the nominal use of other sources.

"For now, the question is why we didn’t put the range of sources in our recent coverage ten years on from the invasion."

That's just one of the
questions I put. You have, quite obviously, ignored or sought to avoid the
others.

"When
looking at Iraq ten years on, we wanted to give a sense of the scale of what has
happened over time and only the Iraq Body Count figures are able to do
that."

Any true sense of scale
would want to show how many war-related fatalities had actually occurred. Are
you seriously arguing that only IBC has been able to provide that qualitative
data? Are you really claiming that a methodology based only on registered media
reports, with all the limitations that entails, is any way to quantify a serious
war death figure?

"If you
look at the graph in this case, the movements are so small as to be
imperceptible. As previously explained, what
matters here is the pattern over a number of years."

No, what fundamentally
matters to the public is the actual number of people dead in this period, not
patterns over the years.

"Other agencies cannot
provide this information so the Middle East editor felt that IBC was the right
source in this instance."

They most certainly can,
and have done. This is a truly shocking evasion and an insult to viewers'
intelligence.

"Using other studies as
well – based on different methodologies – would have been pointless and
confusing for readers."

Again, this is
an utterly deceitful and patronising excuse. Are you actually suggesting that
other research bodies involved here are unable to provide such informed data
and simple explanation? Are you seriously proposing that the public at
large would be either indifferent to or unable to comprehend basic
figures from the Lancet or ORB studies?

I am not satisfied that the key questions contained in my complaint were even acknowledged, never mind answered. I will now pass on my complaint to the BBC Trust for consideration.

Regards

John Hilley

-------------------------------

I trust the above provides sufficient indication of the questions I still wish considered, together with the particular information I'm seeking.

To reiterate the two main requests, as derived from my initial letter and second stage exchange:

I've suggested that, for balanced information, the BBC could show not just an IBC count, but the wider range of sources and their respective data. Why has the BBC consistently refrained from doing so?

I've also asked for specific information on who at the BBC made the editorial decision to adopt IBC as a principal source, to the almost blanket exclusion of the other sources noted, and how that decision was arrived at.

Please could you fully address these two main concerns and give your view on whether the almost sole use of IBC figures maintains a biased and limiting understanding of Iraq war deaths.

Please be reminded that information on the true scale of war-related deaths should be conveyed as a matter of vital public importance by the BBC. As indicated by the recent Com Res poll (noted in the above correspondence), there appears to be a shocking absence of such public awareness. I would ask you to consider this as substantive evidence for my complaint over the BBC's selective and misguided use of IBC figures.

I look forward to your considered deliberations.

Kind regards

John Hilley-----------------------------------Update: response from BBC Trust

Dear
Mr Hilley

I am
writing to acknowledge receipt of your appeal which we received on 19 July 2013.

We
will now consider your request for a final appeal under the BBC’s Editorial
complaints procedure. In order to do this we will review your complaint and your
previous correspondence with the BBC and decide whether your appeal qualifies
for consideration by the Trust. We will only consider the points you raised at
Stage 2 that you want the Trust to reconsider. Therefore, unless there are
exceptional circumstances, we will not consider new points at this stage. We
also ask that you do not now submit any further documentation unless you
consider this to be necessary for the purposes of your appeal.

The
Trust’s Editorial complaints procedure explains that we will write to you with
our decision within 40 working days of the receipt of your appeal (i.e. by 16
September 2013), but we are usually able to do this sooner. We will also keep
you informed if for any reason we meet with delay during this
process.

If we
decide your appeal qualifies to be considered by the Trust, we will write
explaining the process and setting out the timescale for taking your appeal. In
considering whether or not an appeal qualifies for consideration, we may decide
to take only part of the appeal, and consider only some of the issues
raised.

If our
conclusion is that your appeal, or any part of your appeal, does not qualify for
consideration by the Trust, we will write and explain the reasons for that. If
you disagree with our view then you may ask the Trust to review the decision by
writing to us within 10 working days of the date on which you received our
response.

If we
decide your appeal qualifies for consideration, or if you challenge the decision
of the Trust Unit not to proceed with some or all aspects of your appeal, the
matter will be considered at the next monthly Editorial Standards Committee
meeting. We aim to provide you with their final decision within 80 working days
of our decision to accept your appeal or challenge.